October 20, 2015

Douglas A. McKinney

3601 Century Dr

Hastings, MN 55033

Cell (651) 226-6171

Email rivermcks@comcast.net

US Department of Transportation

Docket Management System

1200 New Jersey Ave. SE

Washington DC 20590

RE: Exemption Request Section 333 the FAA Reform Act of 2012

Attachments:

1) Copy of Airline Transport Pilot license 

2) Copy of current First Class Medical Certificate

3) Phantom F550 User Manual

4) NAZA Flight Controller User Manual M V2.0 

5) Bluetooth Datalink & iPad Ground Station User Manual

6) Zenmuse H3-3D Camera Gimbal User Manual

References:

1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0418 in the matter of

 the petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0S08 in the matter of

 the petition of ADVANCED AVIATION SOLUTIONS, LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-03SS in the matter of

 the petition of FLYING CAM INC
Dear Sir or Madam,

In accordance with the FAA's Guidelines for Submitting Petition for Exemption under Section 333 of the

FAA Modernization and Reform act of 2012, I Douglas A. McKinney, referred to hereafter as the 

petitioner, request exemption to the following sections of Title 14, Code of Federal Regulations:

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a) 91.407(a){1); 91.409(a)(1); 91.409(a)(2);

91.417(a)&(b) In order to operate small unmanned aircraft systems (sUAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA) for the purposes of Aerial Photography, 

Cinematography, Videography, Inspections and other flight operations that could be performed safely 

and more cost effectively with the use of a sUAS at low altitude within the US National Airspace System 

as compared to a manned aircraft. Operations will only be performed at the request of and with the

authorization and consent of clients and their authorized agents in order to facilitate commerce and

raise awareness of beneficial uses of sUAS. So long as such operations are conducted within and under 

the conditions outlined herein or as may be established by the FAA as required by section 333. The 

conditions identified and proposed by the petitioner are drawn from references 1-3.

The FARs

The petitioner seeks the exemption from the above mentioned FARs for the following reasons: 61.113(a) 

& (b): The petitioner requests relief in order to facilitate utilization of pilots who hold a PRIVATE PILOT 

(or greater) certificate. Any pilots operating under this exemption would be required to comply with any 

conditions as set forth and in a similar fashion as the previously granted exemptions. 91.119(c) As 

discussed in Exemption 11139 (Douglas Trudeau), operations conducted closer than 500 feet to the 

ground may require that the UA be operated closer than 500 feet to essential persons or objects that 

would not be possible without additional relief. The petitioner requests modification, waiver or 

exemption and clarification concerning the terms of "congested areas" and "densely populated." The 

petitioner requests waiver for this condition to allow reasonable and responsible operations in areas of 

subdivisions and neighborhoods. 91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU), this is 

inapplicable since the sUAS does not have an altimeter and instead utilizes GPS with a barometric sensor 

for altitude information. 91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS 

LLC) prior relief has been granted for manned aircraft to operate at less than prescribed minimums 

including Exemption NO.s 2689, 5745, and 10650. In addition similar sUAS specific relief has been 

granted an Exemption No.s 8811, 1080, and 10673 for daytime, VFR operations. The sUAS provides 

battery power remaining in volts to the PIC. The sUAS batteries provide approximately 15 minutes of 

powered flight. Information provided in the operating documents discusses procedures regarding 

remaining battery power management. The documents contain a condition in which the PIC will initiate 

a landing procedure when the battery remaining reaches a specified level. Given the limitations on 

proposed operations and the location of those proposed operations, the FAA found that a reduced 

minimum power reserve for flight in daytime VFR conditions was reasonable. 91.405(a); 91.407(a); 

91.409(a) (1) & (2); 91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), the 

petitioner proposes to inspect and ensure the sUAS is in a condition for safe flight in accordance with 

the operating documents. 
The FAA found that adherence to the petitioners operating documents and the conditions and 

limitations specified, describing the requirements for maintenance, inspection and record keeping, were 

sufficient to ensure that safety would not be adversely affected.

The sUAS

The DJI Flame Wheel F550 is a highly successful consumer grade small rotorcraft in the hexacopter 

configuration with an advertised weight of less than 5.5 pounds (2400g) designed primarily to carry a 

high definition camera aloft. The F550 has a demonstrated maximum speed of less than 30 kts and a 

maximum climb rate of less than 1000 fpm (5 m/s). The F550 is powered by 6 electric motors with a 

distance between the motors of less than 22 inches (550 mm). The F550 has a NAZA-M V2 Flight 

Controller (FC) that utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor 

to augment with Global Positioning System (GPS) to maintain its geospatial orientation and position. It is 

controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry 

information is transmitted back to a ground station allowing the Pilot In Command (PIC) to monitor 

battery level in volts, GPS signal strength and integrity, altitude (AGL), distance from the PIC, camera 

imagery, and control camera angle. The FC has a failsafe mode of operation for loss of RC or ground 

station signal which causes the sUAS to automatically return to its home take off point, or until RC signal 

is regained. In the event of GPS signal loss, the FC failsafe is to revert to attitude stability mode for 

manual operation. Altitude and distance can be limited by the onboard flight controller and maximum 

altitude/distance can be preprogrammed by the PIC. In addition, the ground station maintains an active 

database of “NO FLY ZONES” situated around airports. Battery life limits flight times to approximately 15

minutes including reserve. The onboard flight controller will alert the pilot via telemetry data and

external lighting cues before reaching a low battery state. An automatic termination of flight and landing 

will be initiated when battery reaches a predetermined low state. It is anticipated that flights will usually 

last less than 10 minutes leaving an adequate 5 min reserve for safe landing. More information is 

available in attachments 3,4,5 and 6.

Risk Mitigation

The petitioner has reviewed FAA exemptions references 1-3 Conditions and Limitations section and

believes that the procedures specified therein are reasonable and will be utilized in order to manage

and mitigate risk and ensure public safety. A preflight and post flight checklist will be developed and

employed to ensure that sUAS airworthiness will be maintained for flight operations. Flight time and

maintenance logs will be maintained to ensure tracking on failure prone components. The petitioner 

requests that in a manner similar to reference 3, he be allows to operate within 5 miles of an airport 

provided that: "The UAS may not operate in Class B, C or D airspace without written approval of the FAA 

The sUAS may not operate within five nautical miles of the geographic center of a non towered airport as 

denoted on o current FAA-published aeronautical chart unless a letter of agreement with that airport's 

management is obtained, and the operation is conducted in accordance with a NOTAM as required by 

the operator's GOA. The letter of agreement with the airport management must be made available to 

the Administrator upon request. "Operations within 5 miles of an airport are not anticipated to be 

routine, but the petitioner is requesting a mechanism to facilitate such activities without requesting a 

new and separate exemption should the need arise. Operations within class B airspace are not 

requested due to the lack of a mode C transponder.
Public Interest

Use of the sUAS in lieu of a manned aircraft would enhance safety and reduce environmental impact

compared to similar operations conducted with much larger fuel laden manned aircraft. Additionally,

the use of sUAS to facilitate commerce can help to encourage economic growth. 

Operations for this petition will enable service for property owners or their designees seeking an 

enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects 

that cannot be displayed through ground level videography/photography. Aerial photography is a 

valuable marketing tool that can facilitate increased commerce and enhance personal photography. 

Crop surveying and inspections could lead to decreased use of pesticides and fertilizer and conservation 

of water as well as increased crop yields and decreased costs. Aerial surveying and inspections can 

increase work site efficiency, improve volumetric estimations and reduce risk. The petitioner will provide 

clients with the photographic data for these purposes in a for hire basis acting as an independent 

contractor. A visual observer (VO) will be utilized. Flight data including sUAS flight time, Control unit 

operation time, incident, accident, and details concerning any deviations from normal operations will be 

available to the FAA for use in collecting data regarding the use of sUAS as a part of this application. This 

data can be submitted to the FAA via reports as required by the FAA.

Conclusion

The petitioner is requesting this exemption for the purposes of "aerial photography, cinematography,

videography, mapping, inspections and other flight operations." The reason for such a general and broad 

based request is that the petitioner wishes to utilize a strategy that allows maximum flexibility to utilize 

the sUAS to its fullest potential within the constraints of this request, without the long turnaround time 

associated with additional exemptions. The petitioner plans to offer services to individuals or companies 

seeking to enhance their business in a safe and lawful way. The petitioner knows that there is extensive 

demand for lawful aerial photography and videography. The petitioner has greater than 2500 hours 

flying experience and holds an Airline Transport Pilot license with 3 aircraft type ratings. He is a current 

certified Multi-Engine Instrument Flight Instructor as well as holds a current First Class Medical 

certificate and is a current member of the Academy of Model Aeronautics (AMA#864065). The 

petitioner owns the sUAS, DJI Flame Wheel F550 which he has flown from his own property and various 

other locations with owner consent to develop flight and photography experience. He has executed 

many takeoffs and landings, has greater than 30yrs experience building and flying RC aircraft, and 

demonstrated continuous proficiency. He has experience with the fail safe modes of the aircraft, having 

run himself through non-normal procedures as described in the DJI NAZA-M V2 Flight Controller

operating manual.

The petitioner plans to utilize the sUAS below 400' AGL, within visual line of sight (VLOS), within 2000'

laterally of the PIC, and with a visual observer at all times.

Respectfully,

Douglas A. McKinney